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Thus, the Authorized Representative's explanation for reduced N.P.
being due to only reduced turnover cannot be accepted as in 2009-10 on
Shri Ramesh Kumar Gupta, Jaipur Vs DCIT, Jaipur
similar turnover the N.P. was 2.30%. Further, the expenditure has
increased even when the turnover has decreased. The Authorized
Representative's submissions that expenditure remains fixed is not in
order when the turnover reduces to half, the expenditure is bound to
decrease and the same is evident as in A.Y. 2009-10 the N.P. rate is
2.32%. The increase in sales commission and freight and cartage
has not been explained satisfactorily while in the case of sales
commission a general reply has been given that commission
bearing sales have increased, freight and cartage is claimed to
be reimbursed in which case it should not affect the profit. In
view of the discussion as above, the rejection of books and estimation of
NP at previous year percentage is upheld."